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1,979 results for “transfer pricing”+ Section 90clear

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Key Topics

Section 143(3)83Addition to Income65Section 14A47Disallowance47Section 115J23Section 6823Transfer Pricing23Deduction22Section 92C19

DCIT, CIRCLE 3(4), MUMBAI, MUMBAI vs. TATA CONSULTANCY SERVICES LIMITED, MUMBAI

ITA 2243/MUM/2025[2018-19]Status: DisposedITAT Mumbai30 Dec 2025AY 2018-19
Section 92CSection 92C(3)

Section 92CA(1) of the Act.\n2.1.4 The transfer pricing adjustments are contrary to the principles laid down\nby the Hon'ble Mumbai Tribunal in the Appellant's own case for the A.Y. 2005-06\n(DCIT vs. Tata Consultancy Services Limited) and therefore are required to be\nquashed and deleted.\n2.1.5 The Id. CTT(A) erred

ACCENTURE SERVICES P.LTD,MUMBAI vs. ADDL CIT RG 3(1), MUMBAI

In the result, assessee’s appeal is partly allowed

ITA 7686/MUM/2012[2008-09]Status: DisposedITAT Mumbai20 Jul 2018AY 2008-09

Bench: Shri Saktijit Dey & Shri Rajesh Kumar

For Appellant: Shri P.J. Pardiwallaa/w

Showing 1–20 of 1,979 · Page 1 of 99

...
Section 26318
Double Taxation/DTAA16
Section 143(2)15
For Respondent: Shri Saurabh Deshpande
Section 10ASection 143(3)Section 154Section 92C

section 133(6) of the Act was made available to the assessee. He has not properly evaluated all the objections of the assessee. The DRP also upheld the finding of the Transfer Pricing Officer by simply observing that the services provided by the company are largely in the nature of software services. Notably, in case of Invensys Development Centre India

ACCENTURE SERVICES P.LTD,MUMBAI vs. DCIT CIR 3(1), MUMBAI

In the result, appeal is partly allowed

ITA 1671/MUM/2014[2009-10]Status: DisposedITAT Mumbai28 Jun 2019AY 2009-10

Bench: Shri Saktijit Deyand Shri N.K. Pradhan

For Appellant: Shri P.J. Pardiwalaa/w Shri Hiten ChandeFor Respondent: Shri Anand Mohan
Section 143(3)Section 144C(13)

Transfer Pricing Officer, the assessee itself admitted that an amount of ` 90,41,87,522, received under the IPSA is in the nature of ITES and can be treated at par with ITES rendered under the DCA and can also be benchmarked considering same comparables. However, an amount of ` 8,47,34,817, received towards services rendered under the IPSA

FIRMENICH AROMATICS (INDIA) P. LTD,MUMBAI vs. ACIT 9(3)(1), MUMBAI

In the result, the appeal filed by the assessee is partly allowed

ITA 6081/MUM/2018[2014-15]Status: DisposedITAT Mumbai07 Jun 2019AY 2014-15

Bench: Shri G Manjunatha () & Shri Ravish Sood () Firmenich Aromatics (India) Vs Acit-9(3)(1), Mumbai Pvt Ltd, 9Th Floor, Arena Space, Cts 20, New Shyam Nagar Road, Behind Majas Bus Depot, Jogeshwari (E), Mumbai. Pan : Aaacf1621M Appellant Respondednt

Section 143(3)Section 144C(5)

Transfer Pricing (*TP') adjustment in relation to export of finished goods 1.1. On the facts and circumstances of the case, and in law, the Hon'ble DRP has erred in upholding the action of the Ld. AO/TPO in determining the Arms' Length Price ('ALP') of the international transaction of export of finished goods at Rs. 10,35,77,048 instead

ASST CIT (LTU) 1, MUMBAI vs. IPCA LABORATORIES LTD, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3691/MUM/2016[2009-10]Status: DisposedITAT Mumbai29 Aug 2022AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

Transfer Pricing Officer to compute the same. iv. With respect to the deduction under Section 80IB and 80IC of the Act, he upheld the disallowance to the extent of the sale of empty containers. He held that sale of scrap is not eligible for deduction as income derived from the industrial undertaking. v. With respect to the claim of depreciation

ACIT CEN CIR 13, MUMBAI vs. IPCA LABORATORIES LTD, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 7511/MUM/2010[2005-06]Status: DisposedITAT Mumbai29 Aug 2022AY 2005-06

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

Transfer Pricing Officer to compute the same. iv. With respect to the deduction under Section 80IB and 80IC of the Act, he upheld the disallowance to the extent of the sale of empty containers. He held that sale of scrap is not eligible for deduction as income derived from the industrial undertaking. v. With respect to the claim of depreciation

IPCA LABORATORIES LTD,MUMBAI vs. DCIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 8084/MUM/2010[2006-07]Status: DisposedITAT Mumbai29 Aug 2022AY 2006-07

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

Transfer Pricing Officer to compute the same. iv. With respect to the deduction under Section 80IB and 80IC of the Act, he upheld the disallowance to the extent of the sale of empty containers. He held that sale of scrap is not eligible for deduction as income derived from the industrial undertaking. v. With respect to the claim of depreciation

IPCA LABORATORIES LTD,MUMBAI vs. DCIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3267/MUM/2012[2007-08]Status: DisposedITAT Mumbai29 Aug 2022AY 2007-08

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

Transfer Pricing Officer to compute the same. iv. With respect to the deduction under Section 80IB and 80IC of the Act, he upheld the disallowance to the extent of the sale of empty containers. He held that sale of scrap is not eligible for deduction as income derived from the industrial undertaking. v. With respect to the claim of depreciation

IPCA LABORATORIES LTD,MUMBAI vs. ASST CIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3597/MUM/2016[2009-10]Status: DisposedITAT Mumbai29 Aug 2022AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

Transfer Pricing Officer to compute the same. iv. With respect to the deduction under Section 80IB and 80IC of the Act, he upheld the disallowance to the extent of the sale of empty containers. He held that sale of scrap is not eligible for deduction as income derived from the industrial undertaking. v. With respect to the claim of depreciation

DCIT CENT. CIR. 5(2), MUMBAI vs. IPCA LABORATORIES LTD., MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 5227/MUM/2016[2010-11]Status: DisposedITAT Mumbai29 Aug 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

Transfer Pricing Officer to compute the same. iv. With respect to the deduction under Section 80IB and 80IC of the Act, he upheld the disallowance to the extent of the sale of empty containers. He held that sale of scrap is not eligible for deduction as income derived from the industrial undertaking. v. With respect to the claim of depreciation

IPCA LABORATORIES LTD,MUMBAI vs. ASST CIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 2493/MUM/2015[2008-09]Status: DisposedITAT Mumbai29 Aug 2022AY 2008-09

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

Transfer Pricing Officer to compute the same. iv. With respect to the deduction under Section 80IB and 80IC of the Act, he upheld the disallowance to the extent of the sale of empty containers. He held that sale of scrap is not eligible for deduction as income derived from the industrial undertaking. v. With respect to the claim of depreciation

IPCA LABORATORIES LTD,MUMBAI vs. DCIT LTU, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3811/MUM/2016[2010-11]Status: DisposedITAT Mumbai29 Aug 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

Transfer Pricing Officer to compute the same. iv. With respect to the deduction under Section 80IB and 80IC of the Act, he upheld the disallowance to the extent of the sale of empty containers. He held that sale of scrap is not eligible for deduction as income derived from the industrial undertaking. v. With respect to the claim of depreciation

IPCA LABORATORIES LTD,MUMBAI vs. ACIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 8120/MUM/2010[2005-06]Status: DisposedITAT Mumbai29 Aug 2022AY 2005-06

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

Transfer Pricing Officer to compute the same. iv. With respect to the deduction under Section 80IB and 80IC of the Act, he upheld the disallowance to the extent of the sale of empty containers. He held that sale of scrap is not eligible for deduction as income derived from the industrial undertaking. v. With respect to the claim of depreciation

DCIT (LTU) 1, MUMBAI vs. IPCA LABORATORIES LTD, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 2815/MUM/2015[2010-11]Status: DisposedITAT Mumbai29 Aug 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

Transfer Pricing Officer to compute the same. iv. With respect to the deduction under Section 80IB and 80IC of the Act, he upheld the disallowance to the extent of the sale of empty containers. He held that sale of scrap is not eligible for deduction as income derived from the industrial undertaking. v. With respect to the claim of depreciation

J.P MORGAN ADVISORS INDIA P.LTD,MUMBAI vs. DCIT RG 3(2), MUMBAI

In the result, appeal is partly allowed

ITA 990/MUM/2014[2009-10]Status: DisposedITAT Mumbai19 Jun 2019AY 2009-10

Bench: Shri Saktijit Dey & Shri Manoj Kumar Aggarwal

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Anand Mohan
Section 143(3)Section 144C(13)

section 234B and 234D of the Act. 70. Levy of interest being consequential is not required to be adjudicated at this stage. 71. In the result, appeal is partly allowed. ITA no.1754/Mum./2014 Revenue’s Appeal – A.Y. 2009–10 72. The grounds raised by the Revenue are corresponding to grounds no.1 and 2 of ITA no.990/Mum./2014. In view

ZEE ENTERTAINMENT ENTERPRISES LIMITED,MUMBAI vs. ADDL. COMM OF INCOME TAX RANGE-11 (1), MUMBAI

In the result, appeal of the assessee is partly allowed

ITA 3406/MUM/2014[2008-09]Status: DisposedITAT Mumbai05 May 2017AY 2008-09

Bench: Shri G.S.Pannu & Shri Ravish Soodzee Entertainment Enterprises Ltd., 135, Continental Building, Dr.A.B.Road, Worli, Mumbai 400 020 Pan:Aaacz 0243R ...... Appellant Vs. The Addl. Commissioner Of Income Tax, Range -11(1), 4Th Floor, Room No.434, Aaykar Bhavan,M.K.Road, Mumbai – 400 020 .... Respondent

For Appellant: Shri Vijay MehtaFor Respondent: S/Shri N.K.Chand &
Section 143(3)

section 92CA(3) of the Act dated 31/10/2011 computing the arm's length price of the international transaction, which was in variance with the stated value of such transactions. Before the Transfer Pricing Officer, assessee pointed out that it was purchasing as well as producing in- house general entertainment programmes, current affairs and films for telecasting on its channels

VAN OORD INDIA P.LTD,MUMBAI vs. DCIT RG 5(3), MUMBAI

In the result, the appeal of the assessee is treated as partly allowed for statistical purposes

ITA 720/MUM/2015[2010-11]Status: DisposedITAT Mumbai11 Nov 2019AY 2010-11

Bench: Shri. A. D. Jain & Shri Rajesh Kumar

For Appellant: S/Shri Nishant Thakkar, RishiFor Respondent: Shri Rajeev Harit, D.R
Section 115VSection 143(3)Section 144C(13)Section 28Section 43CSection 92Section 92(1)Section 92CSection 92C(4)Section 92E

transfer pricing provisions begin from section 92 and end with 92F. They are contained in chapter X in the special provisions relating to avoidance of tax. As such, it is not correct to interpret that the scheme of Tonnage Tax will override the provisions of section 92 to 90

VIACOM 18 MEDIA P.LTD,MUMBAI vs. ADDL CIT 11(1), MUMBAI

In the result, assessee‟s appeal for A

ITA 8754/MUM/2010[2006-07]Status: DisposedITAT Mumbai03 Sept 2021AY 2006-07

Bench: Shri C.N. Prasad & Shri S. Rifaur Rahman

90. Ground no.5, relates to transfer pricing adjustment of ` 52,95,875, on account of payment for use of trademark and programming content under new business model. 91. Facts of this issue are, under the new business model, the assessee received right to use trademark of the channels owned by the A.Es and the programming content owned

ZENZI PHARMACEUTICAL INDUSTIES PVT LTD.,MUMBAI CITY vs. CIT (TRANSFER PRICING)-4, MUMBAI CITY

In the result all the four appeals filed by the assessee are dismissed

ITA 2005/MUM/2023[2019-20]Status: DisposedITAT Mumbai29 Nov 2023AY 2019-20

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Devendra Jain &For Respondent: Shri Vivek Perumpura
Section 131Section 143Section 147Section 148Section 263Section 271BSection 68Section 92C

section 263 of The Income Tax Act, 1961 (The Act) holding that the order passed by the Ld. Transfer Pricing Officer-4(3)(1), Mumbai (“the Ld. TPO”) u/s 92CA 93) of the Act is erroneous and prejudicial to the interest of the revenue and therefore the Ld. TPO was directed to make a fresh order u/s 92CA

ZENZI PHARMACEUTICAL INDUSTIES PVT LTD.,MUMBAI vs. CIT (TRANSFER PRICING)-4, MUMBAI

In the result all the four appeals filed by the assessee are dismissed

ITA 2002/MUM/2023[2012-13]Status: DisposedITAT Mumbai29 Nov 2023AY 2012-13

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Devendra Jain &For Respondent: Shri Vivek Perumpura
Section 131Section 143Section 147Section 148Section 263Section 271BSection 68Section 92C

section 263 of The Income Tax Act, 1961 (The Act) holding that the order passed by the Ld. Transfer Pricing Officer-4(3)(1), Mumbai (“the Ld. TPO”) u/s 92CA 93) of the Act is erroneous and prejudicial to the interest of the revenue and therefore the Ld. TPO was directed to make a fresh order u/s 92CA